permitted 33 test wells to be sealed in 2004_ This action closed off the only avenue through which it is possible to discover what toxins or radiation may be migrating from the site into the community.

While the EPA asserts that testing has been adequately conducted at ML, and that there is no need for further testing, we don't believe this to be accurate. CCLT has consulted with several top private sector and government radiation experts over the years, and has established a broad consensus that the testing for plutonium and other man-made nuclear materials has been, frankly, botched.

EPA measured gross alpha and gross beta, using USEPA Method 900 for Finished Drinking Water, at the IEL Superfund site to screen for radiation in raw, untreated water. However, scientists - including your own - have questioned using this Method on  raw, untreated water. Because the gross alpha/beta method was developed decades ago for naturally-occurrⁱng, water-soluble isotopes (i.e. the uranium-radium series), there is serious concern that due to inherent biases it may be missing crucial particles of insoluble man-made radioactive materials (that may, nevertheless, migrate through enhanced transport mechanisms such as colloids).

Those inherent biases include the Method's focus on the aqueous phase rather than the particle phase. This focus can underestimate or, worse, completely miss man-made nuclear materials not usually expected to be found in the aqueous phase_ because these more-or-less insoluble materials can bind to colloidal materials and migrate through ground water, measuring gross alpha/beta is inadequate. In particular, field filtering - as was done in the 1992/1993 round of testing at TEL - and not preserving samples with acid upon collection - as in the 2000/2001 round - can compromise the integrity of the particle phase of water samples. It is in this phase that one would expect to find plutonium, for instance, if it were present in ground water.

Both field filtering and the failure to acidify immediately upon collection have the same outcome: they can both result in, serious underestimation of plutonium. For years, the argument used by EPA's NAREL to justify the practice has been that, as long as particles are collected on the filters and added back to the solution, there is a full accounting. However, experts do not agree. When samples are not preserved with acid in the field, a condition is created which can allow almost all of the plutonium to precipitate out of the solution to the container walls. A significant portion of it may not, therefore, be analyzed. It is important to note that experts report that even if acidification is done at a later time, there is no guarantee that plutonium will be retrieved from the container walls. There is no guarantee that all (or even a majority) of the plutonium will be accounted for- Furthermore, there have been long-standing and well­documented concerns within EPA and the scientific community that field filtering can compromise results, particularly those related to colloidal material. (Please see USEPA's Kerr Lab documents.)

This issue is broader than questionable testing at ILL. EPA has stated that the ad-hoc Science Advisory Board (SAB) panel assembled to review, among other things, the use of Method 900 at IEL and other similar Superfund sites determined that Method 900 was an adequate screening method. However, it has been confirmed that the majority of that panel did